Brunel responds to the SEC proposed rule change

Brunel Pension Partnership Limited (Brunel) has issued a letter to the Securities and Exchange Commission (SEC) regarding proposed changes to the rules governing proxy voting under SEC rule 14a-8.

Brunel’s key points in response to the consultation are:

  • much more is needed to support the exercise of good stewardship, but the SEC proposals risk aggravating rather than support this change.
  • we strive to get more investors to be good stewards, no matter what size, the SEC proposals risk creating a barrier to progress.
  • it is our role, as investors who employ Proxy Advisory providers, not regulators to hold them to account for quality and professionalism with which they execute their services.
  • shareholder resolutions are a vital part of the investor tool kit and are an opportunity to companies to be made aware of investor concerns.
  • there can be valid reasons for changes in legal title of ownership, whilst the intrinsic beneficial ownership is more long-term.
    improvements in the ‘voting system’ itself could address concerns of transparency and conflict of interest.

In summary, the evidence does not support the proposals being presented, and if implemented, would significantly suppress good governance, the exercise of shareholder rights and our ability to act as good stewards.

To see Brunel’s response in full view it here.

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